Privacy Policy (Local Account)
This privacy policy (hereinafter, the "Privacy Policy") corresponds to the use of the software offered through the mobile application called "Garpa" available on Google Play (hereinafter, the "Application") provided by GARPA S.A. with CUIT No. 30-71658957-5, domiciled at Suipacha 1111, 4th floor, Autonomous City of Buenos Aires, Argentine Republic (hereinafter, "Garpa"). This Privacy Policy is supplemented by the information and definitions used in the Terms and Conditions.
Acceptance of the Privacy Policy and registration in the Application grants you the status of Garpa user (hereinafter, the "Users" or the "User" individually, and together with Garpa, shall be considered as the "Parties") and expresses the free, express and informed consent of each and every clause of the Privacy Policy in the version published by Garpa at the time you access the Application or use the Services.
Garpa may update this Privacy Policy at any time. Where applicable, Garpa will obtain your consent again.
1. CONTROLLER OF PERSONAL DATA PROCESSING
1.1. The controller of your personal data processing shall be GARPA S.A. with CUIT No. 30-71658957-5, domiciled at Suipacha 1111, 4th floor, Autonomous City of Buenos Aires, Argentine Republic. Respect for the privacy of your personal data is an essential priority for Garpa. Should you have any questions about the Privacy Policy or its application, you may contact Garpa at any time by sending an email to: help.ar@garpa.money
2. PERSONAL DATA COLLECTED
2.1. Garpa may, through the Application and through its related companies and/or affiliates and/or business partners, request the following personal data (hereinafter, "Personal Data," as applicable), without the following list being exhaustive: (i) First name and surname, (ii) Date of birth, (iii) Address, including country of residence, (iv) Mobile phone number and/or landline number, (v) Email address, (vi) Current occupation, (vii) Marital status, (viii) National Identity Document, identity card and/or passport; if required, an image thereof may be requested, (ix) Sex, (x) Current status before the Financial Intelligence Unit (UIF), (xi) A personal photo in the form of a “selfie”, (xii) IP address, (xiii) Device geolocation data, (xiv) Any public key you share with us, (xv) Recovery codes (2FA), (xvi) Information on how you use our site, (xvii) Financial information, including: transactions, payment history, payment account number, account balance, (xviii) Prepaid card information, (xix) Transaction history, (xx) Authentication information, including: passwords, PIN, and two-factor authentication. Garpa may request you to report whether you are a politically exposed person or a reporting entity.
2.2. As part of the Personal Data collected, Garpa may also, through the Application and through its related and/or affiliated companies and/or business partners, request personal data obtained from specific technical processing relating to your physical, physiological or behavioral characteristics, which allow or confirm your identification (“Biometric Data”). We will use your Biometric Data mainly for authentication and fraud prevention purposes.
2.3. You undertake to guarantee and be responsible for the truthfulness, accuracy, validity and authenticity of the Personal Data and any other information shared through the Application.
2.4. Garpa will process your Personal Data based on the free, express and informed consent you grant through acceptance of this Privacy Policy. In this regard, you agree that Garpa may collect your information through cookies and/or tags or any other automated information detection method provided by the tools available in the Application. The information collected by Garpa may include browsing behavior, IP address, logs, device information and other types of data.
2.5. Likewise, Garpa may collect and/or store your IP (Internet Protocol) number or address for the sole purpose of improving the quality of the Service and the operation of the Application. It may also collect information about the devices on which the Application is installed. Through the IP number, Garpa may identify your devices at the time of login to your account. Likewise, such storage facilitates the diagnosis of any connection problems that may arise between the Application and Users, improving the quality of the Service.
3. USE OF PERSONAL DATA
3.1. Garpa will use and store the information you provide and the information it collects for the purpose of providing the Service and offering continuous improvements to the Application. For this purpose, Garpa will store the information for the maximum period established by Law 25,326 and/or any law that may replace it in the future.
3.2. Garpa may use Personal Data and the information collected for various purposes, such as:
a) To carry out your registration in the Application. For the purpose of using the Services, Garpa will request your Personal Data to store and generate a database;
b) To verify your identity;
c) To identify and prevent fraud, abuse and crimes related to the protection of User safety and the viability of the Application. In this regard, Garpa may use Personal Data to comply with applicable regulations in the Argentine Republic, such as but not limited to:
Anti-Money Laundering and Counter-Terrorism Financing regulations, carrying out actions to validate identity and Know Your Customer or "KYC" processes, identity verification against Politically Exposed Persons, profile and background verification;
Tax reporting regimes for collection, registration, information, auditing and billing at any level of government;
Compliance with requirements from competent administrative or judicial authorities.
d) To provide the various Services offered by the Application;
e) To contact you to provide information about the Application, the Services or offers that match your interests through notifications in the Application or the contact channels you make available. You may cancel the aforementioned notifications at any time by sending an email to help.ar@garpa.money;
f) To protect your rights and ensure compliance with the Terms and Conditions of the Application;
g) To perform tax identification calculations;
h) To develop internal studies and statistics about your interests and behavior in the Application in order to provide continuous improvements to the Services.
3.3. In particular, you grant your express consent for Garpa to cross-check your Personal Data against the database of the National Registry of Persons (hereinafter, "RENAPER") for the purpose of validating your identity and the validity of your national identity document and/or any other document that Garpa deems necessary or is required to investigate by applicable laws.
For the above reasons, in your capacity as the holder of Personal Data, you grant your consent for Garpa, in its capacity as assignee, to cross-check the Personal Data from your National Identity Document against the RENAPER file, considering that:
a) The Personal Data will be processed for the sole purpose of validating your identity and verifying the validity of your National Identity Document for the provision of the Services;
b) The cross-checked data will be destroyed once the validity of the National Identity Document has been verified, and may not be stored, unless there is a legal obligation to the contrary;
c) The data is provided on a mandatory basis, as it is essential to reliably identify the holder, to ensure the correct identification process;
d) You may exercise the rights of access, rectification and deletion of your data at any time and upon your sole request before RENAPER by electronic means, through the Remote Processing (TAD) platform or through the citizen submission service before the Executive Branch.
3.4. Garpa may share the information with other service companies or internet sites or similar entities for the purpose of providing and/or rendering certain functionalities or services and/or improving the quality of the Service.
Generally, such companies or internet sites have their own privacy policies for their protection. In any case, Garpa will make every possible effort to ensure that the privacy of shared information is protected in the best possible manner. Where applicable, Garpa will endeavor to sign express agreements on data protection and information privacy.
In no case shall Garpa be liable for damages caused by the entities, companies and/or internet sites mentioned in this clause, with respect to their duty of protection, confidentiality and privacy of the data they handle.
3.5. You understand and accept that the Application may contain links that redirect to other sites whose owners are in no way affiliated with Garpa. In such cases, Garpa shall not be responsible for the actions of such sites, to which this Privacy Policy shall not apply. We recommend that you read the privacy policy of such sites.
3.6. Notwithstanding the foregoing, Garpa will share information that is duly required and requested by national or international courts or state agencies or their equivalents, without this generating any right of claim in your favor.
4. INFORMATION WE SHARE
4.1. Garpa will not commercialize any Personal Data with third parties. That is, it will not sell, rent or carry out any negotiation related to them with individuals or legal entities unrelated to Garpa. However, for certain services you request, Garpa may transfer, in compliance with the purposes of such services and/or Garpa's Services, to third-party companies so that such services can be provided.
4.2. Your Personal Data may be shared with authorities (such as, for example, the Central Bank of the Argentine Republic, the Financial Information Unit, the Federal Public Revenue Administration, among others), Garpa's partners and other third parties, such as technology infrastructure and data hosting service providers.
4.3. Garpa guarantees that those who intervene in any phase of Personal Data processing are required to comply with applicable regulations and maintain strict confidentiality.
4.4. We may share some of your data with advertising platforms. Before being transmitted, this data is anonymized. The main purpose of this sharing is to exclude our active users from seeing ads, thereby avoiding unnecessary spending on advertising directed at people who already use our Services. You may object to this processing at any time by writing to help.ar@garpa.money.
5. CONFIDENTIALITY AND INFORMATION SECURITY
5.1. Garpa will adopt all reasonable security measures in accordance with applicable regulations to protect your information and prevent access by third parties not authorized by Garpa. The information collected by Garpa will be kept strictly confidential. Access is limited solely to Garpa's employees, collaborators and representatives who need to know the Personal Data to perform their duties and/or develop or improve the Service in accordance with the purposes of its collection and processing mentioned above. Garpa requires its suppliers to meet the same or higher security and confidentiality standards.
5.2. Garpa will not allow access to this information to third parties unrelated to Garpa, except where there is an express authorization or request from the User.
5.3. Notwithstanding the foregoing, Garpa cannot guarantee that unauthorized third parties may not eventually overcome all security measures and use your information improperly. In such cases, Garpa shall not be liable for illegal interceptions and/or violations of its systems or databases by unauthorized persons, nor for the improper use of information obtained through such means.
6. USER RIGHTS
6.1. As a Personal Data subject, you have the following rights: rectification, deletion or updating of your Personal Data, Garpa may deny such requests due to being required or having the right to retain such Personal Data in accordance with applicable legislation.
6.2. You may access, update, delete or correct your personal information through the Application. In the event that this is impossible for any reason, you may send an email to help.ar@garpa.money with the subject line "Personal Data" and a photo of your National Identity Document requesting access, updating, deletion or correction of your Personal Data.
6.3. THE HOLDER OF PERSONAL DATA HAS THE RIGHT TO EXERCISE THE RIGHT OF ACCESS TO SUCH DATA FREE OF CHARGE AT INTERVALS OF NO LESS THAN SIX MONTHS, UNLESS A LEGITIMATE INTEREST IS DEMONSTRATED FOR SUCH PURPOSE IN ACCORDANCE WITH ARTICLE 14, SUBSECTION 3 OF LAW NO. 25,326 OF THE ARGENTINE REPUBLIC. THE ENFORCEMENT AUTHORITY (IN THE ARGENTINE REPUBLIC, THE AGENCY FOR ACCESS TO PUBLIC INFORMATION, THE OVERSIGHT BODY OF LAW NO. 25,326), HAS THE POWER TO HANDLE COMPLAINTS AND CLAIMS FILED IN CONNECTION WITH NON-COMPLIANCE WITH PERSONAL DATA PROTECTION REGULATIONS.
You may contact the AGENCY FOR ACCESS TO PUBLIC INFORMATION through the following addresses: Located at: Av. Pte. Julio A. Roca 710, 2nd Floor - City of Buenos Aires URL www.argentina.gob.ar/aaip, Email: datospersonales@aaip.gob.ar Phone: + 5411-2821-0047.
6.4. We will retain your Personal Data for as long as your relationship with Garpa remains in effect. Once you cease to be a Garpa customer, we will retain your personal information for 10 (ten) years and/or for any additional period required under applicable law.
7. INTERNATIONAL TRANSFER OF PERSONAL DATA
7.1. Solely for the purposes established in this Privacy Policy and in order to provide the Service, Garpa may transfer Personal Data and/or personal information to authorities, Garpa's partners and other third parties, such as technology infrastructure and data hosting service providers (such as but not limited to Amazon Web Services) used in connection with the Service.
In some cases, such as the Argentine Republic, personal information may be transferred outside the country to countries with the same or better levels of protection. In the event that personal information is transferred to countries with lower levels of protection, Garpa will make such transfers subject to adequate safeguards and security measures, such as standard data protection clauses adopted in the respective agreements or approved by the applicable legal authority.
7.2. Consequently, you consent and agree, through this Privacy Policy, that your Personal Data may be transferred to other countries, whether or not they have an adequate standard of protection. The withdrawal of your consent shall not invalidate Garpa's previous actions.
8. MINORS
8.1. In the event that minors under 18 (eighteen) years of age access the Application or the Service, their use must be supervised by parents, guardians or legal representatives. Without prior authorization from parents, guardians or legal representatives, minors under 18 (eighteen) years of age are not permitted to access, nor to provide any Personal Data or any other type of information to Garpa.
9. CHANGES IN CORPORATE STRUCTURE
9.1. Garpa may transfer the information collected from Users in the event of a sale, merger or acquisition of principal assets or any other form of transfer that Garpa may undergo in the future. In the event of such scenarios, Garpa undertakes to adopt reasonable measures to ensure that such information is used in a manner consistent with this Privacy Policy.
10. EXCEPTIONS
10.1. Notwithstanding the provisions of this document, Garpa may disclose your personal information when it believes in good faith that such disclosure is reasonably necessary to: (i) comply with a legal requirement, such as but not limited to, a search warrant, subpoena or court order; (ii) comply with a requirement from a governmental or regulatory authority; and/or (iii) protect the rights, property or safety of Garpa, the Users, or a third party.
11. AMENDMENTS
11.1. Garpa may amend this Privacy Policy whenever it deems appropriate. In the event that the amendments are substantial with respect to the processing of Personal Data collected through the use of the Service, they shall be notified by posting a prominent notice in the Application and/or by sending an email to the address you have declared.
12. CONTACT
12.1. If you have any questions about the Privacy Policy or its application, you should contact Garpa at any time via email at help.ar@garpa.money.
13. REQUEST DATA DELETION
You have the right to delete your Garpa account at any time. To delete your account, open the "profile" section and choose "personal data." At the bottom of the section, you will see an option to "close account." Tap this button and you will be able to confirm that you wish to close your account.
Data classified as restricted or confidential will be securely deleted when no longer needed. Garpa will evaluate the data and deletion practices of external suppliers in accordance with the Third-Party Management Policy. Only third parties that meet Garpa's requirements for secure data deletion will be used for the storage and processing of restricted or confidential data. Garpa will ensure that all restricted and confidential data is securely deleted from company devices before or at the time of disposal. Confidential and restricted printed materials are shredded or otherwise disposed of using a secure method.
14. PROCESSING OF DATA RELATING TO LEGAL ENTITY CLIENTS
Where the client is a legal entity, this Privacy Policy applies to the processing of the personal data of the legal entity and of the individuals associated with it that is collected in connection with the relationship, including its representatives, attorneys-in-fact, signatories, authorized users, members of its management and supervisory bodies, and ultimate beneficial owners.
The legal entity represents that it has a sufficient legal basis to provide Garpa with the personal data of such individuals and undertakes to inform them of the processing described in this Privacy Policy and, where applicable, to have obtained their consent. The legal entity shall indemnify and hold Garpa harmless against any claim arising from the lack of a legal basis or failure to provide such individuals with the required information.
Last Update: September 7, 2026
